Comment on Proposed Processing Changes
June 17, 2011 2 Comments
The comment period on the Proposed Changes to USCIS’s processing of EB-5 Cases ends today (6/17), and I finally did write and email my opinion. I commented on the words “shovel-ready” and “exemplar,” pointed out the revisions to Public Law 107-273 (2002) SEC. 11037(a) implied in the proposal, and offered an alternate suggestion for improving the adjudication process by establishing a separate workflow for Regional Center amendments. You may read the full text of my response here.
I’m very encouraged to see the comment filed by the AILA EB-5 Committee, which expresses a number of points I wanted to make even better than I did.
EB-5 Updates 
Is there any indication appearing after this comment periods, of when these proposals, particularly the I-924/I-526 premium processing availability?
This question was asked repeatedly at the most recent EB-5 stakeholder meeting on 6/30, and Director Mayorkas would only say that the agency understands that people want a response as soon as possible but it really can’t even estimate when processing changes might begin to be implemented. My sense is that we’re not going to see premium processing availability any time soon, as the proposal is ambitious and will require internal adjustments and revised forms in order to implement.